We use privacy-by-default, cookieless analytics.

Optional analytics cookies are used only if you accept them.

Read our Terms of Use and Privacy Policy.

TemplateEU DSA

DSA transparency report template fields and cadence

This outline helps scope a Digital Services Act transparency report against the harmonised EU templates, not an invented internal report format.

It separates annual Article 15 reporting, online-platform additions, six-month reporting, statement-of-reasons database evidence, and publication records.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
8 sections7 primary sources
Overview

The DSA should start from the official CSV/XLSX templates in Commission Implementing Regulation (EU) 2024/2835. Build one report per service, complete the quantitative and qualitative templates that apply to the service tier, publish the report in a machine-readable and easily accessible format, and keep each published version available for the required retention period.

Section 1

Applicability matrix for the template

Do not use one flat template for every service. The implementing regulation states that the reporting obligations under Articles 15, 24 and 42 are not identical, and the first column of the official templates marks which rows apply to which providers.

Complete this matrix before collecting data so teams do not add unsupported fields or omit rows that apply to their service.

  • All intermediary-service providers in scope of Article 15: report identification, Member State orders, applicable content-moderation information, automated-means information, and the qualitative template rows marked for all providers.
  • Hosting services, including online platforms: include Article 16 notice-and-action data where the official template marks the row for hosting services or online platforms.
  • Online platforms: add internal complaint-handling, out-of-court dispute settlement, repeat-misuse suspension, trusted-flagger, and statement-of-reasons evidence where those obligations apply.
  • Micro or small intermediary-service providers that are not VLOPs are treated differently under Article 15(2); record the basis for any exemption instead of publishing a blank invented report. Recommendation 2003/361/EC sets the tests at fewer than 10 staff and no more than EUR 2 million annual turnover or balance-sheet total for a microenterprise, and fewer than 50 staff and no more than EUR 10 million for a small enterprise, with partner and linked enterprises counted as required.
  • VLOPs and VLOSEs: apply Article 42 reporting at least every six months. Under Implementing Regulation (EU) 2024/2835, the harmonised periods are 1 January to 30 June and 1 July to 31 December; include the rows such as language-level automated-means data, moderator resources for VLOPs, and average monthly active recipients by Member State.
Section 2

Report identification and publication block

Start every service report with the identification fields from the official quantitative template. Treat these as publication metadata, not as a marketing cover page.

The publication record should be enough for a reader, auditor, or Digital Services Coordinator to tell which service, reporting period, version, and previous report the file relates to.

  • Name of the service provider.
  • Name of the service, using the same name across the CSV/XLSX file, public landing page, statement-of-reasons database account, and prior reports.
  • Date of publication of the report and date of publication of the latest previous report.
  • Starting date and ending date of the reporting period.
  • Version label when a prior report is corrected, with a short explanation of the changed figures, methodology, and correction date.
  • Public URL where the report is available, plus any accessible summary or XLSX copy if published alongside the required machine-readable file.
Section 3

Cadence and retention fields

The template should contain explicit cadence fields because Article 15 reports and Article 42 reports run on different publication rhythms.

Use the official dates only where they are supported by the implementing regulation. The transition matters: the templates applied to content-moderation data collected from 1 July 2025, the first template-based period was 1 July to 31 December 2025, and the first full harmonised annual cycle for other covered providers is 1 January to 31 December 2026.

  • Annual DSA transparency reports for intermediary services, hosting services, and online platforms cover 1 January to 31 December once the harmonised cycle applies.
  • VLOPs and VLOSEs publish at least every six months for the harmonised periods 1 January to 30 June and 1 July to 31 December.
  • Transition record: for the 2025 transitional cycle, distinguish data before 1 July 2025 from data collected under the Annex I instructions from 1 July 2025. Do not describe 2025 as a full harmonised annual cycle.
  • Reports must be publicly available no later than two months after the reporting period ends.
  • The harmonised templates apply from 1 July 2025; the first full annual harmonised cycle for non- providers covers 1 January to 31 December 2026.
  • The first cycle using the harmonised templates covers 1 July to 31 December 2025.
  • Retain transparency reports, including all published versions, for at least five years after publication.
Section 4

Quantitative tables to include

Use the official quantitative template sections as the spine of the report. Each table should keep the official applicability, service, reporting period, indicator, scope, value, and contextual-information logic so figures remain comparable across services.

Where a row applies and the result is zero, enter 0. Where the row cannot apply to the provider or service, leave it blank rather than forcing an invented zero.

  • Member State orders to act against illegal content: category of illegal content, Member State scope, number of orders, number of specific items, median time to acknowledge receipt, and median time to give effect.
  • Member State orders to provide information: category, Member State scope, number of orders, median acknowledgement time, and median time to give effect.
  • Article 16 notices: number of notices, trusted-flagger notices, number of specific items, action basis, automated processing, and median time to take action.
  • Own-initiative content moderation: number and type of measures affecting availability, visibility, accessibility, user ability to provide information, or monetisation, broken down by detection method and restriction type where required.
  • Online-platform redress: internal complaint-handling outcomes, out-of-court dispute settlement outcomes, implemented decisions, and suspensions for repeat misuse under the platform rows.
  • Automated means: number of measures or notices processed using automated means and indicators such as accuracy, precision, recall, and possible error rate where the official row applies.
  • additions: content-moderation human resources and linguistic expertise for VLOPs, and average monthly active recipients by Member State for VLOPs and VLOSEs.
Section 5

Qualitative narrative fields

The qualitative template should explain how the numbers were produced and what the moderation system did during the reporting period. It is not a substitute for the quantitative CSV/XLSX tables.

Keep qualitative text tied to the official indicators. Avoid adding generic policy statements that do not explain the reporting period, the service, or the measurement method.

  • Summary of content moderation engaged in at the provider's own initiative.
  • Meaningful and comprehensible information about own-initiative content moderation, including the policies, detection sources, and restriction types reflected in the quantitative rows.
  • Qualitative description of automated means used for content moderation.
  • Description of the indicators of accuracy and possible rate of error for automated means.
  • Specification of the precise purposes for which automated means are applied.
  • Safeguards applied to the use of automated means.
  • High-level description of the content-moderation governance structure.
  • For VLOPs where applicable: qualifications, training, support, and methodology for computing human resources dedicated to content moderation.
Section 6

Statement-of-reasons and DSA Transparency Database evidence

A transparency report is not the same as the DSA Transparency Database submission process, but the two datasets should reconcile for online platforms covered by Article 24(5). Article 17 explain individual moderation restrictions to users, while Article 24(5) requires covered online platforms to send those statements to the Commission database; Article 19 can exclude qualifying micro and small providers from that platform-section duty.

Use the database as supporting evidence for online-platform reporting, especially for moderation restrictions, grounds, automated processing, free-text explanation fields, and the difference between public database data and internal source-of-record artifacts.

  • Keep a reconciliation table with report section, internal moderation-event source, statement-of-reasons submission count, DSA Transparency Database field, and variance explanation.
  • Do not include personal data in public database submissions; the Commission FAQ says providers must remove personal data before publication in the database.
  • Do not treat the database as a repository of the moderated content itself; it records and accompanying decision information, not the underlying content.
  • Account for the database retention policy when preserving evidence: the cited Commission FAQ gives 180 days for search, 540 days for downloadable daily CSV dumps, and five years for dashboard aggregates. The Commission may change this operational policy; it is not a statutory provider-retention period.
  • For large data extracts, record whether evidence came from full or light daily archives because light archives omit certain long free-text attributes and territorial scope.
Section 7

Evidence tables to keep behind the public report

The public report should stay aligned with the official template. Keep operational evidence in supporting tables so reviewers can reproduce the figures without adding unofficial fields to the published CSV.

Each evidence table should identify the source system, extraction time, aggregation rule, owner, and reconciliation status for the official template row it supports.

  • Orders evidence table: order identifier, issuing Member State, legal basis or category, received timestamp, acknowledgement timestamp, action timestamp, item count, source queue, and report row.
  • Notice-and-action evidence table: notice identifier, notifier type, trusted-flagger status, item count, alleged illegality category, action basis, action timestamp, automation flag, and report row.
  • Own-initiative moderation evidence table: detection source, policy or law ground, restriction type, affected item count, user-notification status, statement-of-reasons link where applicable, and report row.
  • Complaints and dispute evidence table: complaint or dispute type, original decision, outcome, reversal status, median-time source, implementation status for out-of-court decisions, and report row.
  • Automated-means evidence table: tool name, precise purpose, measure or notice population, human-review rule, accuracy metric source, precision/recall source, error-rate explanation, safeguard, and report row.
  • evidence table: designation status, active-recipient calculation source, Member State breakdown, and report row; for VLOPs, also include the moderator headcount source, language expertise method, and evidence for linguistic expertise.
  • Publication evidence table: public URL, CSV encoding check, XLSX copy if used, publication date, previous-report date, version label, correction note, retention review date, and source owner.
Section 8

Pre-publication checks

Before publication, check the report against the official template instead of against an internal checklist alone. The strongest review asks whether every required official row is complete, blank for a valid reason, or zero because the practice could have occurred but did not.

Keep the review short and reproducible so later corrected versions can explain exactly what changed.

  • The service tier is documented and every official applicability row has been assessed.
  • The quantitative and qualitative templates are both present, or any omission has a specific and objective reason.
  • Counts are integers, percentages are floating values in the 0 to 1 interval, and median times are stated in hours.
  • Rows that apply but produced no activity use 0; rows that cannot apply to the service are blank.
  • Illegal-content and incompatible-content categories reconcile to the official category logic and do not use provider-created high-level categories.
  • The public file is , UTF-8 encoded, and made easily accessible; any XLSX or narrative summary is supplementary.
  • All public versions remain available for at least five years and corrected versions are explicitly marked.
Recommended next step

Turn DSA reporting rows into evidence-backed tables

Sorena can help map your service tier, reporting period, official CSV/XLSX rows, statement-of-reasons evidence, and publication records into a reviewable DSA transparency-report package.

Research workflow
Open Research Copilot for DSA reporting

Ask questions tied to cited sources about Article 15, Article 24, Article 42, statement-of-reasons data, and the harmonised reporting templates.

Explore next step
Talk to Sorena
Review the reporting template

Check which DSA transparency-report rows apply to your service tier and which evidence tables are needed before publication.

Explore next step
Primary sources

References and citations

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates
eur-lex.europa.eu8 citations
Referenced sections
  • Official implementing regulation for the harmonised DSA transparency-report CSV/XLSX templates, reporting periods, publication deadline, retention, versioning, and template instructions.
  • Supports the use of the official CSV/XLSX templates, the different applicability rows for Articles 15, 24 and 42, and the micro or small provider distinction.
  • Supports the report identification fields, one-report-per-service instruction, publication format, versioning, and five-year retention requirement.
Show 5 more
  • Supports the reporting periods, publication deadline, template application date, transition cycles, and five-year retention period.
  • Supports the quantitative template sections for orders, notices, own-initiative moderation, complaints, out-of-court disputes, automated means, moderator resources, and active-recipient reporting.
  • Supports the qualitative template indicators and the instruction that omitting required template parts without a specific objective reason makes the report incomplete.
  • Supports the evidence categories by specifying the official rows, measurement units, CSV/UTF-8 requirements, contextual-information columns, zero-versus-blank treatment, and versioning expectations.
  • Supports the validation checks for completeness, formats, units, category handling, zero-versus-blank treatment, and retention.
"shall use the CSV- or XLSX-version of the templates"
More quoted passages
"not all sections of the templates apply to all types of service providers"
"publish one transparency report in accordance with the templates in Annex I per service"
"at the latest by two months after the date of the conclusion of each reporting period"
"consisting of eight sections"
"consisting of one section"
"Where a row applies to a provider, but the result of that practice is zero"
"must comply with the CSV standard RFC 4180 and must use UTF-8"
Regulation (EU) 2022/2065 (Digital Services Act)
eur-lex.europa.eu4 citations
Referenced sections
  • Primary DSA legal text for Articles 15, 17, 24, 33 and 42 transparency-reporting, statement-of-reasons, online-platform, and VLOP/VLOSE obligations.
  • Primary DSA legal text for Articles 15, 24 and 42 transparency reporting obligations.
  • Primary DSA source for annual Article 15 reporting and six-month Article 42 reporting by VLOPs and VLOSEs.
Show 1 more
  • Primary DSA source for Article 17 statement-of-reasons requirements and Article 24 platform transparency obligations.
"clear and specific statement of reasons"
More quoted passages
"providers of online platforms shall include in the reports referred to in that Article information"
"at least once every six months"
European Commission - DSA Transparency Database Q&A
digital-strategy.ec.europa.eu3 citations
Referenced sections
  • Commission FAQ for Article 17 statements of reasons, Article 24(5) database submissions, database access, personal-data exclusion, daily downloads, and retention periods.
  • Supports the distinction between Article 17 statements of reasons, Article 24(5) database submissions, public database access, personal-data removal, and database retention periods.
  • Supports keeping source evidence for statements-of-reasons submissions, database downloads, light versus full archives, and retention limitations.
"The database is publicly accessible and machine-readable."
More quoted passages
"The DSA Transparency Database only records statement of reasons."
"The full archive files contain all variables"
European Commission - DSA guidance on publishing user numbers
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission guidance on average monthly active recipients, which supports VLOP/VLOSE threshold and active-recipient evidence fields.
  • Commission guidance supporting the active-recipient data point used for VLOP/VLOSE identification and reporting.
"average monthly active recipients of the service"
More quoted passages
"average monthly active recipients of the service in the Union"
European Commission - How the Digital Services Act enhances transparency online
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission transparency page explaining the DSA transparency-reporting context and linking the harmonised implementing regulation to public DSA report transparency.
  • Commission page linking DSA transparency reporting to the harmonised implementing regulation and public report accessibility.
"templates for the transparency reports"
More quoted passages
"implementing regulation laying down templates for the transparency reports"
European Commission - VLOPs and VLOSEs under the DSA
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission source for VLOP/VLOSE designation context, including the over-45-million monthly EU user threshold and enhanced obligations.
  • Commission source for the VLOP/VLOSE size threshold and enhanced DSA obligations.
"more than 45 million users per month in the EU"

Related guides

DSA Ads and Recommender Systems: transparency duties, user choice, and evidence

An official source DSA guide to ad labels, targeting restrictions, recommender parameter disclosure, non-profiling options for VLOPs and VLOSEs, ad repositories, and compliance evidence.

DSA Applicability Test: classify intermediary services, platforms, marketplaces, VLOPs and VLOSEs

A cited EU Digital Services Act applicability test for classifying intermediary services, hosting services, online platforms, marketplaces, VLOPs and VLOSEs.

DSA Article 28 minors protection guide for online platforms

EU Digital Services Act guide to Article 28 minors protection: platform scope, child-safety measures, targeted ads limits, recommender controls, and official source evidence.

DSA Complaint and Dispute Workflows for Online Platforms

Build DSA complaint, appeal, statement-of-reasons, and out-of-court dispute workflows for online platform moderation decisions.

DSA crisis response for VLOPs and VLOSEs

EU Digital Services Act crisis response guide for VLOPs and VLOSEs: Article 36 Commission decisions, Article 48 crisis protocols, mitigation, governance, requests for information, and records.

DSA Dark Patterns: interface design checks for online platforms

Article 25 DSA guidance for reviewing online platform interfaces for deceptive, manipulative, or choice-distorting design patterns.

Show all related guides (35)

DSA Enforcement and Penalties in the EU

How Digital Services Act enforcement works: Commission and Digital Services Coordinator roles, VLOP and VLOSE investigations, fines, periodic penalty payments, and evidence readiness.

DSA Marketplace Trader Traceability Guide

EU Digital Services Act guide for online marketplaces collecting, checking, displaying, storing, and evidencing trader traceability information.

DSA notice and action plus statements of reasons guide

A source-cited Digital Services Act guide for notice intake, moderation decisions, statements of reasons, DSA Transparency Database submission, complaints, appeals, trusted flaggers, and records.

DSA Notice and Action Workflow for Hosting Services and Online Platforms

A source-cited DSA notice-and-action workflow covering notice intake, completeness checks, trusted flaggers, decisions, user communications, statements of reasons, appeals, and records.

DSA researcher data access for VLOPs and VLOSEs

Article 40 DSA guide to vetted researcher access for VLOPs and VLOSEs under Regulation (EU) 2025/2050: requests, data catalogues, security, deadlines, and records.

DSA service tier classifier for platforms, marketplaces, VLOPs and VLOSEs

Classify a digital service under the EU Digital Services Act as intermediary, hosting, online platform, marketplace, VLOP or VLOSE, with EU recipient-count evidence and obligation outputs.

DSA statement of reasons log workflow for online platforms

Build a DSA statement of reasons log for moderation decisions, Transparency Database submission, complaint links, retention, and QA controls.

DSA Transparency Reporting Obligations by Provider Tier

A source-cited guide to EU Digital Services Act transparency reports, active-recipient publication, statements-of-reasons submissions, VLOP/VLOSE reports, templates, cadence, and evidence.

DSA VLOP and VLOSE Risk Assessments and Mitigation Guide

A source-cited guide to Digital Services Act systemic risk assessments, mitigation measures, audits, transparency reports, data access, and governance evidence for VLOPs and VLOSEs.

DSA VLOP Audit Pack Workflow: Risk, Mitigation, Audit, and Transparency Records

Build a DSA VLOP or VLOSE audit pack covering Article 34 risk assessments, Article 35 mitigations, independent-audit evidence, transparency reports, data access, and compliance governance.

DSA vs DMA Platform Rules

Compare the EU Digital Services Act and Digital Markets Act by scope, designation thresholds, obligations, enforcement, evidence, and practical team ownership.

DSA vs GDPR: online-platform governance and personal-data obligations

Compare the EU Digital Services Act and EU GDPR by scope, ads, recommenders, minors, transparency, complaints, enforcement, and evidence.

DSA vs P2B Regulation: EU platform obligations compared

Compare the EU Digital Services Act with the Platform-to-Business Regulation for platform scope, business-user terms, content moderation, ranking transparency, complaints, enforcement, and evidence.

DSA vs Terrorist Content Online Regulation: notice-and-action vs removal orders

Compare DSA content-governance duties with the EU Terrorist Content Online Regulation removal-order workflow for scope, timing, evidence, authorities, and team ownership.

EU Digital Services Act checklist for platforms and hosting services

An official source DSA checklist for classifying service tiers, notice-and-action, statements of reasons, complaints, transparency reports, ads, recommenders, trader traceability, VLOP/VLOSE duties, and evidence records.

EU Digital Services Act Compliance Guide

DSA compliance guide for intermediary services, hosting providers, online platforms, marketplaces, and VLOP/VLOSE teams: obligations, controls, and evidence to keep.

EU Digital Services Act FAQ: DSA scope, platform duties, VLOPs, reports, and penalties

Concise EU Digital Services Act FAQ covering intermediary-service scope, active-recipient thresholds, illegal-content notices, statements of reasons, trader traceability, recommender transparency, systemic-risk duties, reporting, penalties, and complaints.

EU Digital Services Act penalties and fines: caps and enforcement roles

DSA penalty caps and enforcement roles: Member State fines, Commission fines for VLOPs and VLOSEs, 1% procedural fines, and 5% periodic penalty payments.

EU Digital Services Act requirements by service tier

Overview of DSA obligations for intermediary services, hosting providers, online platforms, marketplaces, VLOPs and VLOSEs, including notices, complaints, ads, transparency reports, audits, data access and enforcement.

EU Digital Services Act service types and scope

Classify DSA service scope across mere conduit, caching, hosting, online platforms, marketplaces, online search engines, and VLOP/VLOSE threshold duties.

EU DSA deadlines and compliance calendar: application dates, reporting cycles, and VLOP clocks

Calendar view of cited EU Digital Services Act dates: full application, user-number publication, VLOP/VLOSE designation clocks, statements of reasons, and transparency reporting cycles.

EU DSA Transparency Calendar: reports, statements of reasons and user counts

Build a DSA transparency calendar for annual reports, statement-of-reasons database submissions, active-recipient updates, and VLOP/VLOSE audit touchpoints.

EU DSA vs UK Online Safety Act: scope, duties, regulator, and evidence

Compare the EU Digital Services Act and UK Online Safety Act for platform scope, risk assessments, child protection, transparency, regulators, enforcement, and owners.

DSA average monthly active recipients: what platforms must publish

An official source FAQ on average monthly active recipients under the EU Digital Services Act, including publication, EU recipient scope, the 45 million VLOP/VLOSE threshold, and evidence records.

DSA illegal content notices: what must be included?

An official source FAQ on EU Digital Services Act illegal-content notices: Article 16 notice elements, acknowledgement, decision notices, trusted flagger priority, statements of reasons, and records.

DSA Marketplace Trader Traceability FAQ

Answer to what EU Digital Services Act Article 30 requires online marketplaces to collect, verify, display, retain, and evidence for trader traceability.

DSA recommender transparency FAQ: Article 27 and VLOP options

What EU Digital Services Act recommender transparency requires: main parameters, user options, VLOP/VLOSE non-profiling choices, and evidence to keep.

DSA statement of reasons FAQ

When DSA statements of reasons are required, what they must contain, when online platforms submit them to the DSA Transparency Database, and what appeal records to keep.

DSA VLOP Risk Assessment FAQ: Article 34, Mitigation, Audits

What VLOPs and VLOSEs must assess under the EU Digital Services Act, when to reassess, how Article 35 mitigation and annual audit evidence fit together, and what records to keep.